david a.swank northw estdavid a.swank columbia generating station p.o. box 968, pe04 northw est...

David A.SwankColumbia Generating Station

P.O. Box 968, PE04Richland, WA 99352-0968NORTHW EST Ph. 509.377.2309 1 F. 509.377.4150

[email protected]

Proprietary - Withhold under 10 CFR 2.390. Enclosure I contains PROPRIETARYinformation.

August 6, 2013G02-13-1 11

10 CFR 50.90U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

Subject: COLUMBIA GENERATING STATION, DOCKET NO. 50-397RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATEDTO LICENSE AMENDMENT REQUEST TO IMPLEMENTPRNMIARTSIMELLLA

References: 1) Letter, G02-12-017, dated January 31, 2012, BJ Sawatzke (EnergyNorthwest) to NRC, "License Amendment Request to Change TechnicalSpecifications in Support of PRNM /ARTS / MELLLA Implementation"(ADAMS Accession No. ML1 2040A072)

2) Letter dated July 10, 2013, NRC to ME Reddemann (Energy Northwest),"Columbia Generating Station - Request for Additional InformationRelated to License Amendment Request to ImplementPRNM/ARTS/MELLLA (TAC NO. ME7905)" (ADAMS Accession No.ML13179A128)

Dear Sir or Madam:

By Reference 1, Energy Northwest requested approval of a license amendment requestto revise the Columbia Generating Station Technical Specifications to reflectimprovements in the Average Power Range Monitor / Rod Block Monitor TechnicalSpecifications (ARTS) and expand the facility operating domain to reflect operationsusing the Maximum Extended Load Line Limit Analysis (MELLLA). Theseimprovements coincide with the installation of the digital General Electric-Hitachi (GEH)Nuclear Measurement Analysis and Control (NUMAC) Power Range NeutronMonitoring (PRNM) System.

Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additionalinformation related to the Energy Northwest submittal. Transmitted herewith inEnclosure I is the response to the request for additional information (RAI).

When Enclosure 1 is removed from this letter, the letter and remaining Enclosuresare NON-PROPRIETARY.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO 'LICENSEAMENDMENT REQUEST TO IMPLEMENT PRNMWARTS/MELLLA

There are no new regulatory commitments identified with this response. Should you haveany questions or require additional information regarding this matter, please contactMs. L. L. Williams, Licensing Supervisor, at (509) 377-8148.

Enclosure 1 contains proprietary information as defined by 10 CFR 2.390. GEH, as theowner of the proprietary information, has executed the affidavit, included in Enclosure 3,which identifies that the enclosed proprietary information has been handled andclassified as proprietary, is customarily held in confidence, and has been withheld frompublic disclosure. The proprietary information was provided to Energy Northwest in aGEH transmittal that is referenced by the affidavit. The proprietary information hasbeen faithfully reproduced in the respective Enclosure such that the affidavit remainsapplicable. GEH hereby requests that the enclosed proprietary information be withheldfrom public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17.Information that is not considered proprietary is provided in Enclosure 2.

I declare under penalty of perjury that the foregoing is true and correct. Executed on thedate of this letter.

Respectfully,

DA SwankAssistant Vice President, Engineering

Enclosure 1 - Response to RAls, Enclosure 1 of GEH Letter GE-MS-CT-1 06244-JC25,"GEH Responses to NRC EICB RAIs 22-28," (Proprietary)

Enclosure 2 - Response to RAIs, Enclosure 2 of GEH Letter GE-MS-CT-106244-JC25,"GEH Responses to NRC EICB RAls 22-28," (Non Proprietary)

Enclosure 3 - Affidavit for Enclosure 1

cc: NRC Region IV AdministratorNRC NRR Project ManagerNRC Senior Resident Inspector/988CAJ Rapacz - BPA/1 399 (email - Enclosure 2 & 3)WA Horn - Winston & Strawn (email - Enclosure 2 & 3)JO Luce - EFSEC (email - Enclosure 2 & 3)RR Cowley - WDOH (email - Enclosure 2 & 3)

Enclosure 2

GE-MS-CT-106244-JC25

GEH Responses to NRC EICB RAls 22-28

Non-Proprietary Information-Class I (Public)

No*-Proprietary Notice

This is a non-proprietary version of the Enclosure 1 of GE-MS-CT-106244-JC25 which has theproprietary information removed. Portions of the document that have been removed areindicated by an open and closed bracket as shown here [[ fl.

Enclosure 2 Non-Proprietary Information - Class I (Public)GE-MS-CT- 106244-JC25 Page 2 of 13

With regard to Staff Position 20 of Digital Instrumentation and Controls DI&C-ISG-04,Revision 1, "Task Working Group #4: Highly-Integrated Control Rooms--CommunicationsIssues (HICRc), Interim Staff Guidance," dated March 6, 2009 (ADAMS AccessionNo. ML083310185), the licensee has stated that [[

]]. If this test data is available by middle ofAugust 2013, please provide a summary of the test results. If such data is not likely to beavailable by August 31, 2013, please provide the date by which the data will be available forCGS.

Data error rate testing was completed in October of 2011 and the test data is available.

]]The table below summarizes thetest results.

[[

The test results validate that the observed data error rates are less than or equal to the establisheddesign basis error rates.

Enclosure 2 Non-Proprietary Information - Class I (Public)GE-MS-CT-106244-JC25 Page 3 of 13

Recirculation flow signal processing electronics are being replaced by integrated digitalNUMAC chassis based APRM electronics. The APRM is to be designed such that any singleshort or open of any one of the flow inputs will not affect the other flow inputs. EnergyNorthwest has stated that [[

f]. Please confirm how the flow transmitter signal to local power range monitor(LPRM) system will be isolated such that there is no adverse effect on the safety system due to anopen circuit, a short circuit, or a ground fault. Since the eight flow transmitters are not safetyrelated, Energy Northwest is requested to clarify how the safety to non-safety interface andsignal isolation is achievedfor the flow transmitters.

The flow transmitter signals and local power range monitor (LPRM) detectors enter theLPRM Input Modules within the average power range monitor (APRM) instruments. [[

]] These devices provide the isolation to prevent adverse effects on the safety systemdue to an open circuit, a short circuit or ground fault in the LPRM detectors or flowtransmitter signals.


In order to determine that Rod Manual Control System (RMCS) to Rod Block Monitor (RBk)communication link will not be subject to a broadcast storm, the licensee is requested to confirmwhether the data communicated over the serial link from the RMCS to the RBM is fixed andvalidated prior to use. If not, please explain how data broadcast storm is avoided such thatadverse effects on the functioning of RBM are prevented

GEH JUmansThe design and implementation of the Columbia Generating Station (CGS) RBM ensures that abroadcast data storm from the RMCS to the RBM does not have an adverse effect on thefunctioning of the RBM.

]]

Therefore, there are no adverse effects on the functioning of the RBM in the event of a databroadcast storm.


NRC RAI 25

Table 1, Columbia NUMAC PRNM Licensing Topical Report (LTR) Deviations in0000-0101-7647-R3 (ADAMS Accession No. MT12040A073) lists three exceptions.Exception (a) states that Oscillation Power Range Monitor (OPRM) Upscale function is voted withAPRM INOP [inoperable] Function with the justifcation that it improves operating flexibility.The PRNM licensing basis, as described in the in the document cited above, is that "OPRMUpscale function is voted separately from the APRM INOP function. " The justification for thisdeviation is to improve operational flexibility. As the licensee states,

This deviation allows using the APRM chassis keylock switch to place APRM andOPRM outputs from a second channel in the tripped condition when anotherAPRM/OPRM channel is already bypassed (and cannot be returned to servicewithin the allowed out of service time) without having to resort to other actionssuch as disconnecting a fiber-optic cable to the 2-out-of-4 voters or removingpower from the APRM chassis.

Section 8.4.1.3 of NEDC-32410P', Supplement 12 states, in part, that combining the OPRMupscale with the APRMINOPfunction could result in unnecessary trips. Unnecessary trips areconsidered nuisances and challenges to the safety system. Based on the rationale provided inSection 8.4.1.3 of NEDC-32410P, Supplement 1, please furtherjust6fy this change with the regardto spurious trips.

G- HUnse

The concern about unnecessary trips was because of the limited operational experience withOPRMs at the time LTR Supplement 1 was written. Note that Section 8.4.1.3 of Reference 25-1states [[

]] With over 200 plant-years of operational experience with installedOPRMs, those uncertainties no longer remain. This LTR deviation has been part of otherapproved NUMAC PRNM license amendment requests, including Grand Gulf Nuclear Station(Reference 25-2) and Monticello Nuclear Generating Plant (Reference 25-3). No unnecessarytrips due to this design feature have been reported.

Reference

25-1. GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range NeutronMonitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-32410P-A, Supplement 1, November 1997.

NEDC-32410P-A, "'Nuclear Measurment Analysis and Control Power Range Neutron Monitor (NUMACPRNM) Retrofit Plus Option III Stability Trip Function, Volumes I and 2, " October 1995 (ADAMS LegacyAccession No. 9605290009).2 NEDC-3241OP-A, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMACPRNM) Retrofit Plus Option III Stability Trip Function, Supplement I '" November 1997 (ADAMS Legacy AccessionNo. 9806120242).


25-2. NRC Letter, "Grand Gulf Nuclear Station, Unit 1 - Issuance of Amendment RE: PowerRange Neutron Monitoring System Replacement (TAC NO. ME253 1)," dated March 28,2012 (ADAMS Accession No. ML120400319).

25-3. NRC Letter, "Monticello Nuclear Generating Plant (MNGP)-Issuance of AmendmentRegarding the Power Range Neutron Monitoring System (TAC NO. MD8064)," datedJanuary 30, 2009 (ADAMS Accession No. ML083440681).


NRK RAI 26

Table I, Columbia NUMAC PRNMLTR Deviations in 0000-0101-7647-R3 (ADAMS AccessionNos. MI1204OA081 (non-public) and ML1204OA073 (public)) lists three exceptions and thesecond exception (Exception b) states that time to calculate the Flow-biased Trip Setpoint takesmore than the allocated time in LTR NEDC-32410P-A, Volume 14, Section 3.3.2, with theexplanation that ([

1]

Section 3.3.2 of NEDC-3241OP-A, in part states that:[1

1]

]] The NRC staff is concerned that the intent of the trip may not bemet for fast transients due to the excessive response time. Pleasefurt her justify this deviation forback up protection against all transients. In addition, please cite any precedence with regard tothis deviation, •f available.

Columbia has Rosemount recirculation flow transmitters that are typical and widely used in theindustry. They are unaffected by a PRNM retrofit. The time constant of these transmitters[[I

]] This deviation was discovered during the Columbia project. [C

]] Becausethe topic is not unique to Columbia, GEH notified other customers with installed PRNMsystems.

The processing time is not a concern during fast transients because the STP trip does not protectagainst them. The APRM neutron flux high trip is intended to address fast transients. Bycontrast, the STP trip is intended to provide protection against a slow positive reactivity additionscenario such as Loss of Feedwater Heating, where thermal power increases slowly. While thesequence of events may produce sufficiently high flux levels to initiate an APRM reactorprotection system trip, no credit is taken for a reactor trip on STP in the safety analysis of theevent.


Reference

26-1. GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range NeutronMonitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-3241OP-A Volume 1, October 1995.


NRC RAI127

Table 1, Columbia NUMAC PRNMLTR Deviations in 0000-0101-7647-R3 lists three exceptionsand the third exception (Exception c) states that any missing module in a chassis causes analarm but not necessarily a trip whereas the PRNM licensing basis states that [[

]] Energy Northwest justifies this exception byreferring to the purpose of the APRMINOP trip described in NEDC-32410P-A, Section 3.2.10.1,and stating that [[ 1] is beyond the intent.The NRC staff has not found any statement in NEDC-32410P-A, Section 5.3.8.2 orSection 3.2.10.1, which states this rationale. Therefore, please clarify and further justify thisexception.

Section 3.2.10.1 of Reference 27-1 specifies ((

]] and it is not desirable to cause an Inop trip if such amodule were determined to be missing from the instrument. The system is designed to providean alarm when a module is missing and to provide a trip only when performance of the safetyfunction is affected. Detailed discussion of self-test faults was provided in Reference 27-2.Referen=e

27-1. GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range NeutronMonitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-32410P-A, Volume 1, October 1995.

27-2. GE Nuclear Energy, "Columbia Generating Station Power Range Neutron MonitoringSystem Design Report on Computer Integrity, Test and Calibration, and Fault Detection,"NEDC-33698P, Revision 2, December 2012.


NRK RAI 28

As mentioned earlier, the setpoint calculation audit was conducted by NRC on April 3, 2013.Subsequent to the meeting, the staff observed that there are minor discrepancies between thepreviously provided Figure 9.3.8.1 in GEH setpoint methodology in NEDC-33685P (ADAMSAccession Nos. ML,1204OA082 and ML12040A074) and the response to RAI 18 provided byEnergy Northwest's letter dated October 5, 2012. Figure 9.3.8.1 shows the required limit [[

1] whereas Figure RAI 18-1 shows the [[]I Energy Northwest is requested to explain the noted discrepancy.

GEH Respps:

Overview of the Differences in Information Ia the Figures:

Both Figure 9.3.8-1 in NEDC-33685P (Reference 28-1) and Figure RAI 18-1 (Reference 28-2)indicate the errors considered in the margin between the Technical Specifications AllowableValue (TS AV) and the final adjusted Nominal Trip Setpoint, called "NTSP(ADJ)" and, morerecently, "NTSP Final (NTSPF)." However, the figure provided in the RAI 18 response is asimplified pictorial representation of the GEH setpoint methodology to discuss the pertinentfeatures described in that RAI response. Both figures indicate the same method and procedurefor calculating the Licensee Event Report (LER) Avoidance Margin, but because the calculationprocess is complicated, the figures provided slightly different ways of displaying the process in asimple way. The more detailed Figure 9.3.8-1 displays an intermediate LER Avoidance Margin,corresponding to an intermediate NTSP calculation.

As explained in the description in NEDC-33685P (Reference 28-1) that accompaniesFigure 9.3.8-1, the initial instrument setting, NTSP1 3, might be too close to the AV. If theAV/NTSPI margin is not sufficient for the LER avoidance test, the NTSP is conservativelyadjusted to provide added margin from the AV. The GEH Setpoint Methodology includes amultiple-step process to determine the final NTSP with sufficient margin from the AV for LERavoidance.

The first step is changing NTSPI to NTSP2, an intermediate NTSP, which involves the [f

]]The GEH setpoint methodology performs a Leave Alone Tolerance 4 (LAT) test to determine ifthe NTSP needs to be adjusted further in the conservative direction, as was described in NEDC-33685P (Reference 28-1). This second step in changing to the final adjusted NTSP(ADJ)

3 Note that NTSPI is the Limiting Trip Setpoint (LTSP), as the instrument setting nay be no closer to theAnalytical Limit (AL) than NTSPI.

4 Note per the guidance provided in RIS 2006-17 (Reference 28-3) and TSTF-493 (Reference 28-4), theinstrument setting must be set equal to the Limiting Trip Setpoint after periodic testing. In practice, theinstrument setting is reset to the Final NTSP ±ALT after each calibration. Thus, the LAT is set equal to theALT in the GEH setpoint calculations.


(i.e., NTSPF) also involves determining the [[

]] and may result in anadjustment to the setpoint in the conservative direction to the final adjusted NTSPF.

This two-step methodology was simplified in Figure RAI 18-1 provided in the RAI 18 response(Reference 28-2), as was explained in that RAI response. The methodology for calculating thesetpoints in Figure RAI 18-1 is exactly the same as what was previously described inFigure 9.3.8-1 in NEDC-33685P (Reference 28-1). However, for simplification,Figure RAI 18-1 leaves out the pictorial representation of NTSP2, the intermediate NTSP.Hence, the change from NTSPI to the final adjusted NTSPF shown in that figure includes theinterim steps of [C

]] However, because it is a simplified figure, it does not show the interim steps.For convenience, see Figure RAI 28-1.

Hence, the differences in the two figures are simply differences in notation and there is nodiscrepancy in the setpoint methodology used for the Columbia PRNM!ARTS/MELLLAsetpoint calculations.


[[

11Figure RAI 28-1 GEH Simplifled Setpoint Methodology

Note that for clarity, the figure provided in the response to RAI 7 (Reference 28-2),Figure RAI 7-1, should have been made to be the same as Figure RAI 18-1, so that it wouldindicate that the errors considered in the [[

I]

Summary:

Thus, the final NTSPF includes [


11Also, the final NTSPF includes sufficient margin from the AL as the margin between the AL andthe final NTSP is at least equal to, and generally greater than that needed to meet the 95%probability requirement of Regulatory Guide 1.105. That is, the final adjusted NTSP(ADJ) isgenerally more conservative than NTSP 1, the Limiting Trip Setpoint.

Refren28-1. GE Hitachi Nuclear Energy, "Digital I&C-ISG-06 Compliance for Columbia Generating

Station NUMAC Power Range Neutron Monitoring Retrofit Plus Option III Stability TripFunction," NEDC-33685P, Revision 2, dated December 2012.

28-2. Energy Northwest Letter, "Columbia Generating Station, Docket No. 50-397 Response toRequest for Additional Information Regarding Licensing Amendment Request toImplement PRNMIARTS/MELLLA," G02-12-135, dated October 5, 2012 (ADAMSAccession No. ML122920735).

28-3. NRC Regulatory Issue Summary (RIS) 2006-17, "NRC Staff Position on theRequirements of 10 CFR 50.36, 'Technical Specifications,' regarding Limiting SafetySystem Settings during Periodic Testing and Calibration of Instrument Channels,"August 24,2006 (ADAMS Accession No. ML051810077).

28-4. Letter, TSTF to NRC, "Transmittal of TSTF-493 Revision 4, Errata," TSTF-10-07, datedApril 23, 2010 (ADAMS Accession No. MLI01 160026).

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING UCENSEAMENDMENT REQUEST TO IMPLEMENT PRNIWARTS/MELLLAEnclosure 3

Enclosure 3

Affidavit for Enclosure 1

GE-Hitachi Nuclear Energy Americas LLC

AFFIDAVIT

I, Linda C. Dolan, state as follows:

(1) I am the Manager of Regulatory Compliance, Regulatory Affairs, of GE-Hitachi NuclearEnergy Americas LLC ("GEH"), and have been delegated the function of reviewing theinformation described in paragraph (2) which is sought to be withheld, and have beenauthorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure I of GEH letter, GE-MS-CT-106244-JC25, "ENW-CGS PRNM/ARTS/MELLLA Round 4 RAI Responses," datedJuly 25, 2013. The GEH proprietary information in Enclosure 1, which is entitled "GEHResponses to NRC EICB RAls 22-28," is identified by a dotted underline inside doublesquare brackets. [[, q ý ie '' ' :11 In each case, the superscript notation I

refers to Paragraph (3) of this affidavit, which provides the basis for the proprietarydetermination.

(3) In making this application for withholding of proprietary information of which it is theowner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedomof Information Act ("FOIA'), 5 U.S.C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S.C.Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets(Exemption 4). The material for which exemption from disclosure is here sought alsoqualifies under the narrower definition of trade secret, within the meanings assigned tothose terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass EnergyProiect v. Nuclear Regulatoy Commission. 975 F.2d 871 (D.C. Cir. 1992), and PublkiCitizen Health Research Group v. FDA. 704 F.2d 1280 (D.C. Cir. 1983).

(4) The information sought to be withheld is considered to be proprietary for the reasons setforth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit intothe definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting dataand analyses, where prevention of its use by GEH's competitors without license fromGEH constitutes a competitive economic advantage over other companies;

b. Information that, if used by a competitor, would reduce their expenditure of resourcesor improve their competitive position in the design, manufacture, shipment,installation, assurance of quality, or licensing of a similar product;

c. Information that reveals aspects of past, present, or future GEH customer-fundeddevelopment plans and programs, resulting in potential products to GEH;

d. Information that discloses trade secret or potentially patentable subject matter, or both,for which it may be desirable to obtain patent protection.

(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted toNRC in confidence. The information is of a sort customarily held in confidence by GEH,

Affidavit for Enclosure I ofGE-MS-CT-106244-JC25 Page 1 of 3


and is in fact so held. The information sought to be withheld has, to the best of myknowledge and belief, consistently been held in confidence by GEH, not been disclosedpublicly, and not been made available in public sources. All disclosures to third parties,including any required transmittals to the NRC, have been made, or must be made, pursuantto regulatory provisions, or to proprietary or confidentiality agreements that provide formaintaining the information in confidence. The initial designation of this information asproprietary information, and the subsequent steps taken to prevent its unauthorizeddisclosure, are as set forth in the following paragraphs (6) and (7).

(6) Initial approval of proprietary treatment of a document is made by the manager of theoriginating component, who is the person most likely to be acquainted with the value andsensitivity of the information in relation to industry knowledge, or who is the person mostlikely to be subject to the terms under which it was licensed to GEH. Access to suchdocuments within GEH is limited to a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires reviewby the staff manager, project manager, principal scientist, or other equivalent authority fortechnical content, competitive effect, and determination of the accuracy of the proprietarydesignation. Disclosures outside GEH are limited to regulatory bodies, customers, andpotential customers, and their agents, suppliers, and licensees, and others with a legitimateneed for the information, and then only in accordance with appropriate regulatoryprovisions or proprietary or confidentiality agreements, or both.

(8) The information identified in paragraph (2), above, is classified as proprietary because itcontains the detailed setpoint methodology and design information for the instrumentationand control equipment that is used in the design and analysis of the power range neutronmonitoring system for the GEH Boiling Water Reactor (BWR). These methods, techniques,and data along with their application to the design, modification, and analyses associatedwith the power range neutron monitoring system was achieved at a significant cost to GEH.

The development of the evaluation process, as well as the interpretation and application ofthe analytical results, constitutes a major GEH asset that is derived from the extensive liecycle experience that is recorded in databases for this equipment. Moreover, the proceduredocumentation is generally held as company proprietary throughout the General ElectricCompany. The procedure document discussed with reference to the verification processused by GEH is a part of the overall General Electric Company library of procedures thathas been developed over the company's long history.

(9) Public disclosure of the information sought to be withheld is likely to cause substantialharm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety andtechnology base, and its commercial value extends beyond the original development cost.The value of the technology base goes beyond the extensive physical database andanalytical methodology and includes development of the expertise to determine and applythe appropriate evaluation process. In addition, the technology base includes the valuederived from providing analyses done with NRC-approved methods.

Affidavit for Enclosure I ofGE-MS-CT-106244-JC25 Page 2 of 3


The research, development, engineering, analytical and NRC review costs comprise asubstantial investment of time and money by GEH. The precise value of the expertise todevise an evaluation process and apply the correct analytical methodology is difficult toquantify, but it clearly is substantial. GEH's competitive advantage will be lost if itscompetitors are able to use the results of the GEH experience to normalize or verify theirown process or if they are able to claim an equivalent understanding by demonstrating thatthey can arrive at the same or similar conclusions.

The value of this information to GEH would be lost if the information were disclosed to thepublic. Making such information available to competitors without their having beenrequired to undertake a similar expenditure of resources would unfairly provide competitorswith a windfall, and deprive GEH of the opportunity to exercise its competitive advantageto seek an adequate return on its large investment in developing and obtaining these veryvaluable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein aretrue and correct to the best of my knowledge, information, and belief.

Executed on this 2 5 h of July 2013.

Linda C. DolanManager, Regulatory ComplianceRegulatory AffairsGE-Hitachi Nuclear Energy Americas LLC3901 Castle Hayne Rd.Wilmington, NC 28401

Affidavit for Enclosure 1 ofGE-MS-CT-106244-JC25 Page 3 of 3

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